1. I am over 18 years of age and currently reside in the state
of Minnesota, County of Hennepin. This declaration is of my own
personal knowledge and if called upon to testify to the facts
herein I could and would be competently able to testify thereto.

2. I am intimately familiar with the Scientology organization,
movement and beliefs because I was in Scientology for 16 years
(1976-92) and served in the highest ranks, including as the
second in command of the Religious Technology Center (RTC). At
that time, my position was "Deputy Inspector General, External"
which meant being in charge of all activities outside the body
of Scientology. This included being in charge of all litigation
by or against any Scientology organization, intelligence
(spying, covert operations) brought against perceived or
imagined "enemies" (which ranged from critics to media to the
courts), trademark registrations, and the licensing of
trademarks to other Scientology organizations, which was how we
tightly controlled all Scientology corporations while creating
the false impression of "corporate integrity."

3. It is incumbent on this and every court, as well as the
authorities, to realize the amount of deception, chicanery,
lying, manipulation and outright criminality that Scientology
will employ to hide the truth about their criminal activities.
They will spend any amount of money to do this. I know because I
was part of it for years. I received orders to break the law. I
issued orders to break the law. I got others to break the law,
and then I helped to hide these criminal activities just as they
are hiding them now.

4. In fact, this tactic is one of the most coercive used by the
Scientology hierarchy: to involve members in criminal acts for
which they are then liable, which then prevents the person from
speaking out. Even if the member manages to leave or flee, they
will be reluctant to speak to the courts or the authorities
because they were part of criminal activities. Plus the
organization is ready to use Mafia-like tactics to threaten an
ex-member if the hierarchy is afraid of their testimony. If the
ex-member does speak, the organization will claim no knowledge
and blames the individual, calling them a criminal when that
person was doing nothing more than following orders under duress.

5. Members of Scientology are induced to confess to acts that,
if not outright criminal, are embarrassing or possibly
destructive to the person's job, marriage or profession, for
example, shoplifting, adultery, masturbation, or drug abuse. The
member is urged to write these down in their own handwriting,
under the guise that it is a "religious confessional" for the
member's good. The truth is that these "confessions" are kept to
blackmail and extort the member should they dare to speak out.
The member is also coerced to sign documents that are
self-damaging while protecting the organization, solely in case
the member dares to leave their control and speak the truth. I
know because I watched this done to others, I did it to others
and it was done to me. That is why I respectfully urge this
court to recognize Scientology's tactics and treat them for what
they are: criminal deceit to defraud this court at any cost.

6. For the past five years since I fled Scientology, I have been
silent because it was my intent to create a new life for myself,
away from their obsessive control, and it required all the
energy that I could muster to do that. About two weeks ago, I
finally became curious as to what was happening within the
Scientology world and I used the Internet to look up Scientology
and was stunned to discover former friends who had also left and
the conflicts being waged in the courts. I contacted one (Stacy
Young) who had been a close friend for many years in the cult
who told me what had been happening, with former members
fighting to have the abuses and the criminality exposed.

7. Because I have intimate and personal knowledge of issues in
this case, she put me in touch with attorney Dan Leipold and I
traveled to his offices in Santa Ana, California. After speaking
with him and others, I realized that this level of criminal
fraud and deceit can no longer continue without opposition. I
could no longer remain silent, regardless of their terrorism. I
offered to tell the court how Scientology really operates with
trademarks, copyrights and the courts. In fact, I am doing this
at the risk of enduring the hate campaign this pseudo-religion
will wage against me, as they have against others, including
judges.

8. Let me begin with some basic information about my own
Scientology history: I first became involved with Scientology in
September 1976, in San Francisco. In late 1976 I joined the
elite Scientology paramilitary organization known as the Sea
Organization, also known as the "Sea Org" or the acronym "SO."
The Sea Organization is the actual nexus that controls the
Scientology empire. Sea Organization personnel are authorized to
take over and control Scientology organizations and to demote
personnel, move bank accounts and run the corporation as if the
SO personnel were employees or representatives of that
corporation but they are not. This is true if the organization
was part of the "Church of Scientology" or one of the secular
areas such as Bridge Publications. This is possible because the
only personnel allowed into executive positions in these
organization are those who are in full agreement that the Sea
Organization is the commanding organization. This weeding out
process guarantees there will be no executives who will resist
or protect their corporate integrity. This is how the Sea
Organization can operate with impunity, and continue to claim
that it is merely a "fraternal organization." The Sea
Organization is a "fraternal organization" the way the Cosa
Nostra is.

9. Before I was recruited into the Religious Technology Center
(RTC) in 1982, most of my experience was with Scientology
technical material; the actual codified techniques used within
the organization. This gave me considerable time to become
familiar with the material, most of which was written by
Scientology founder L. Ron Hubbard. It was that familiarity that
prompted my promotion to a technical position at RTC.

10. Physically, I was transferred to and lived and worked at
what is known as "Golden Era Studios," near Hemet, California.
It is also known as "Gold" or simply "the base." RTC's presence
at Gold was fully known to all at the base, but was kept hidden
from all others, to try to make it appear that Gold was merely a
movie/tape production studio when really the movie/tape
production is nothing but a front to mask, hide and protect the
top of Scientology's actual power structure so they cannot be
served with subpoenas. (The security system is more befitting a
top secret military installation, with its motion detectors,
buried sensors, high-speed cameras, night cameras, guards on
motorcycles, and barbed wire fences wired to detect anyone
touching it etc.)

RTC was at that time the most senior, most powerful and most
influential organization in all of Scientology. All at RTC were
Sea Org members, as are all at the base. But because of RTC's
position, we were the elite at the base.

11. In March 1983, I became the Deputy Inspector General,
External, and a member of the Board of Directors for RTC, as
Treasurer. (The only other board members were Warren McShane as
Secretary and Vicki Aznaran as President, during this time.) At
the time I was appointed a member of the Board of Directors of
RTC I was forced to sign an undated letter of resignation. This
is standard practice with all Scientology board members and is
another means by which the Scientology corporations are
controlled while giving the appearance of corporate integrity.

12. In that capacity for the next few years, I traveled about
the US and outside of the US on behalf of RTC. I traveled to
Germany, Italy, Australia, the United Kingdom, Denmark, Mexico
and Canada, with several trips to some of these countries. These
trips were to put together an infrastructure that would then
interface with RTC for the purpose of trademarks. I became
familiar with the law with regard to each area, interviewed and
approved law firms, and put the personnel in place that would
report to RTC and be our on-the-ground representatives in
dealing with the attorneys etc.

13. When Hubbard died in 1986, there was a power struggle in
Scientology for the next 18 or so months that resulted in
Hubbard's closest and most powerful aide (Pat Broeker) being
removed. The power was taken over by David Miscavige who purged
the organization of anyone who was friendly with Broeker. In
mid-1987, I was removed from my position and put under armed
guard at Happy Valley, a property the organization owns that is
a few miles west of Gold and located deep in the Soboba Indian
Reservation. I assume the undated resignation I provided on
being appointed to the Board was then dated and used to make it
appear that I had resigned, when I had not. After a few months,
it was decided that I would not escape and I was given various
jobs at Gold but kept under watch. My pay was standard Sea Org
pay, $24 per week.

14. I should clarify why I (and others) tolerated such treatment
for so long. The ability to tolerate such abusive conditions and
treatment are one of the most basic requirements for promotion
in the Sea Organization and RTC. We were selected and promoted
because we vowed such loyalty and demonstrated it daily. Not
unlike a military unit, it is the ability of the Sea Org member
to take orders, carry out the assignment and to tolerate
self-degrading conditions that ingratiates them to their seniors
and to the system. That was why I was promoted so highly and why
I then tolerated more. Looking back on it, I cannot believe that
I actually tolerated such denigration and such abuse and
actually deluded myself that it was for my good as well as the
good of others.

15. In late 1991, my wife Monika became pregnant and although we
were elated, she was ordered to abort the child. The reason for
the abortion order is that Sea Org members were not allowed to
have children. The order devastated both my wife and me. Our
dedication as Sea Org members clashed violently with our
intentions as parents and we went through a personal nightmare
with me opposing it, to no avail. She got the abortion and
afterwards she was not the same. She was devastated at the
impact of what she did and that was when she told me she wanted
to leave. We fled, with the organization close behind us, trying
to find us. They finally did and convinced us to return so we
could "leave properly."

16. Once they had us again behind the barbwire and watched by
security, my wife was threatened that if we did not sign certain
papers, she would no longer be able to see her father and her
sister, who were both in the Sea Organization.

17. This is another coercive power that the organization wields.
Like a police state, it can order and enforce family members to
alter their relations, and even get them to turn against each
other. Monika and I knew that if the organization said she would
be kept from her father and sister (by control over them), that
she would not again be able to talk to them or see them, let
alone visit. This is called "disconnection" in Scientology. We
agreed to sign the papers and were able to leave.

18. On July 26, 1998, one of the cult's attorneys sent a long
fax to Dan Leipold that is their first not-so-veiled threat to
me, warning me to be silent. The attorney included the document
they prepared for me and that I signed under the conditions I
just described. I am attaching his letter and the documents I
was forced to sign under duress as my first evidence of what
this criminal cult does to silence anyone speaking out. (Exhibit
1). It does not surprise me, as it is a standard tactic, to
force a person to create or sign a self-damaging document to use
when ready.

19. I have also been privy to the destruction and alteration of
documents to protect the group. On or about April of 1983 I was
present at a meeting, which took place in Los Angeles,
California at a Scientology office called Author Services, Inc.
(ASI). ASI presented itself as the "literary agency" for Hubbard
but it was actually the top of the Scientology empire at that
time. All of Scientology was being directed from ASI in 1982.
ASI was where various Scientology corporations went to receive
orders.

20. Present at the meeting was David Miscavige, then the
chairman of the board of ASI, Vicki Aznaran then the Deputy
Inspector General of Religious Technology Center, (RTC) and
Lymon Spurlock, who was "Director of Client Affairs" for ASI.
Mr. Miscavige expressed concern at this meeting that there might
possibly be a raid on Scientology by the IRS. At that time, none
of the churches of Scientology had received tax exempt status.

21. One principle reason why tax exempt status had not been
granted was the IRS's position that Scientology founder L. Ron
Hubbard (LRH) was actually the managing agent of Scientology in
complete disregard of the corporate structure of Scientology. We
knew this to be a fact but also knew that it violated IRS rules
and thus had to be hidden.

22. There was concern that the IRS would obtain the hundreds of
daily, weekly and monthly LRH orders written by Mr. Hubbard and
distributed throughout Scientology. These orders were commonly
referred to in Scientology as "advices" to avoid the appearance
that LRH was actually running Scientology. In fact, LRH was
running Scientology. The principle concern expressed at this
meeting was that the LRH orders or "advices" would be used to
name L. Ron Hubbard as the managing agent of Scientology.

23. Because of an already existing fear that an LRH "advice"
might fall into the wrong hands, these orders from him were
written in a way that we could deny it was from him. His name
was not on them. He was never cited in the dispatch except in
the third person. There was no signature and a salutation in
reply was never more than "Dear Sir." The routing at the top
referred to him merely as "*," an asterisk. However if a person
(or an agency) got enough of these, there would be little doubt
that we were in touch with Hubbard (via ASI) and he was telling
us and each corporation what to do to make him more money.

24. David Miscavige specifically stated that ASI was "already
dealing with the problem", ridding ASI of any documents that
would implicate L. Ron Hubbard as managing agent of Scientology.
He stated that under his directive the LRH orders, or "advices",
were being collected and transferred by truck to a Riverside
County recycling plant where the documents were to be "pulped".
This method of destruction was considered to be better than
shredding. I was also given instructions that I was in charge of
purging the remainder of the Scientology organization of LRH
orders. This was to include Church of Scientology of California
(CSC); Church of Scientology International (CSI); and RTC.

25. Several weeks after this first meeting I attended a second
meeting at the ASI offices concerning the continuing destruction
of Scientology corporate documentation. In attendance at the
second meeting were David Miscavige, Lymon Spurlock, Vicki
Aznaran, Norman Starkey and Marty Rathburn. At this meeting,
David Miscavige for the first time stated that Scientology had
been ordered by a court to produce various documents concerning
a former Scientology member named Lawrence Wollersheim who had a
lawsuit pending in Los Angeles against the Church of Scientology
of California. The court had ordered Scientology to produce Mr.
Wollersheim's entire "preclear" (PC) file.

26. A "PC " file is one of several files kept on members. The PC
file is the file that includes all written records of all
"confessionals" done by the member. This means that it includes
not only the most self-damaging material but it also reflects
every problem the person might have had with the organization,
including complaints. This PC file grows with the person's
tenure in Scientology.

27. Mr. Wollersheim's PC file was several thousand pages in
length and stood as high as a six-foot tall man. Initially at
this meeting it was decided that Mr. Wollersheim's PC file would
be redacted and culled of any evidence or documentation which
might assist Mr. Wollersheim in his lawsuit against CSC. There
was also concern that the materials known as Clear, OT I, OT II,
OT III and NED for OT's (NOTS) would be open to public
inspection if Mr. Wollersheim's files were produced as ordered.
Scientologists are taught that a person could catch pneumonia
and die if that person is prematurely exposed to these "upper
level" materials without first having taken many hours of
preparatory auditing. Ultimately, approximately 50 pages were
produced pursuant to the court order. Mr. Wollersheim's PC file
was culled based on a direct order from David Miscavige.

28. Later, I was informed that a second court order was issued
to produce Mr. Wollersheim's entire file. Faced with the
prospect of having to produce the entire file David Miscavige
gave orders that the entire file simply be destroyed by being
pulped.

29. Pursuant to Mr. Miscavige's orders I ordered Rick Aznaran to
take Mr. Wollersheim's PC files to the recycling plant in
Riverside to be pulped. Several hours after I gave the order to
have Mr. Wollersheim's PC files destroyed, Mr. Aznaran returned
and confirmed that the records had been pulped and even showed
me a small bottle of pulped material, saying "Here's what's
left."

30. The material that David Miscavige ordered destroyed and
which Rick Aznaran had pulped was the same material that the
court had ordered produced in Mr. Wollersheim's Los Angeles
court case against CSC.

31. In early 1983 I attended a meeting at Scientology's ASI
office in Los Angeles. In attendance at this meeting were David
Miscavige, Lymon Spurlock, Vicki Aznaran, Patricia Brice and
Edith Buchele. The meeting concerned Scientology copyrights. In
particular, David Miscavige stated that Scientology was "in
trouble" concerning the copyright status of the many published
materials of founder L Ron Hubbard. Concern was expressed that
many of Mr. Hubbard's published materials had become 'public
domain" because the materials had not been registered with the
United States Copyright office for many years. David Miscavige
stated that Scientology had failed to register copyrights for
thousands of pages of Scientology material written by Mr.
Hubbard. These records included the numerous policy letters and
bulletins published by Mr. Hubbard. In particular, Mr. Hubbard
published "Policy Letters" (always published in green ink on
white paper and intended as administrative directives) LRH ED's
(Executive Directives) which are used for various topics,
(always issued as blue ink on white paper) and "Technical
Bulletins" published with red ink on white paper covering
technical aspect of Scientology such as Auditing techniques,
Policy and Ethics.

32. At the same meeting in early 1983 David Miscavige
specifically ordered Patricia Brice (who at the time was L. Ron
Hubbard's personal secretary and an employee of ASI) to begin
the process of mass copyright registration filings for all of L.
Ron Hubbard's materials. This order was given despite the fact
that Mr. Miscavige was already aware that many of the materials
in question were already in the public domain. Thus, I know from
personal knowledge that in mid 1983 Scientology began a massive
program to register Mr. Hubbard's material with the United
State's Copyright office.

33. Based on my many years of reading and studying Scientology
directives including my time as a "Co-Audit Supervisor" and
"Inspector General Cramming Officer" I became intimately
familiar with the content, form, manner of distribution and
publication of Scientology works and directives including the
works of L. Ron Hubbard. As a Cramming Officer it was my job to
insure that those who employ Scientology "tech" properly adhere
to the official guidelines adopted by Scientology.

34. I was requested by counsel for Mr. Wollersheim to review the
exhibits to BPI's renewed motion for summary judgement. These
were contained in more than 20 banker's boxes.

In reviewing these boxes of exhibits I selected out documents at
random to inspect. The chart below explains the result of my
examination of certain of the exhibits. In examining the
plaintiff's exhibits I compared the alleged LRH originals
submitted by the plaintiff's as exhibits to some early editions
of Scientology compilations which contains the policy issues in
question. I employed a "1st edition" of the Organization
Executive Course, and a "First printing of the Scientology
Technical Bulletins for comparison to what BPI has claimed are
the LRH originals.

35. I have attached hereto copies of various LRH materials that
were published by Scientology in the early 1970's that prove
conclusively that the copy right notices on BPI's purported "LRH
originals" were not present then, but placed on the "originals"
at a later date.

36. The above chart documents my observations in reviewing the
documents that I selected at random to review. The important
points that I believe the Court should note with reference to
these documents are as follows:

1. Exhibits B-1289; 1290; 1291; 1292 and 1293 contain a 1953
copyright notice. However, the copyright registrations submitted
by BPI are for a compilation published in 1955.

2. Exhibits B4; B-94 and B-215 all contain copyright notices
from the 50's, 60's and 70's that contain notations to CSI. CSI
is the Church of Scientology International, which did not come
into existence until 1981. Therefore, either BPI's "originals"
are not originals as claimed, or the copyright notices were
placed on these documents long after they were published.
(Exhibits 2, 3 and 4 attached hereto).

3. Exhibits B-59; B-369; and B-371 contain copyright notices
from 1958. However, when these originals are compared to first
printings or first editions of compilations put out by
Scientology in the 1970's, these copyright notices are not
present, indicating that they were placed in the "originals"
subsequent to the compilations being published. (Exhibits 5-7).

4. Exhibit B-2 is substantially different from that published as
an original in OEC Vol. II, 1st Ed. 1970. (Exhibit 8 attached
hereto).

7. Exhibit B-1 shows on its face it is not an original but
"Issue II."

8. Exhibits B-248; B-249; and B-157 show on their face they were
published elsewhere prior to the claimed original publication.

37. Based on my knowledge gained as a staff member of
Scientology, including my assignment as "Chief Cramming Officer"
and based on my examination of the exhibits submitted by BPI in
support of their renewed motion for summary judgment, it appears
that numerous "originals" submitted by BPI are not originals at
all and that copyright notices were placed on documents long
after publication back-dating them to the date of publication.

Further declarant sayeth naught.

I declare, under penalty of perjury under the laws of the United
States of America and the State of California that the foregoing
is true and correct. Executed this 27th day of July, 1998, at
Santa Ana, California.